The Department of Transportation (DOT) is proposing to require that many air travel websites, as well as automated airport check-in kiosks, be made accessible to people with disabilities. What should the standards for web and kiosk accessibility be? Which websites and how many kiosks should be covered? How long should companies have to make the changes? Data about the benefits, costs, and feasibility of these changes will be very important to DOT’s final decisions.

§1. Importance of good data

DOT first considered website accessibility in a 2004 rulemaking proposal, but it didn’t then have the solid data about society-wide benefits and costs of new standards that it is legally required to have. (See DOT’s discussion of lack of website data). Now, it has collected a lot of data, which is summarized in this post. (You can find all the details in the ”Regulatory Impact Assessment” (RIA)). DOT wants help from you to check the accuracy of its estimates, provide additional information, and point out things it might have missed. Two things to remember: (1) Benefits and costs “count” even if it’s not easy to reduce them to dollars and cents. Many benefits from accessibility may fall in this category. Providing more detail helps DOT take these kinds of benefits and costs into account. (2) Benefits and costs that can be expressed in dollar amounts must be backed up by data; general claims about expenses or savings don’t count for much without specifics.

Who should look carefully at this benefit and cost information?

Travelers with disabilities who will use air travel websites and can describe how DOT’s proposal would affect their travel experience

§2. Benefits for travelers with disabilities

1. Time saved in obtaining information, purchasing tickets, checking in, etc.: DOT estimates that travelers with disabilities currently spend, on average, 1.2 hours per year on inaccessible web sites. Based on a study of 100 users with vision impairments, accessibility would cut this time by about 30%. For all travelers with disabilities predicted to use air travel websites, this adds up to time savings over 10 years valued at $159.78 million (undiscounted). (See RIA Table 21)

2. Decreased travel expenses from improved access to discounted or promotional air fares and other services offered online: Airlines are currently required to give the benefit of web-only specials to travelers who cannot book online because of disabilities, without extra charge for phone assistance. (See 14 C.F.R. § 382.31(c)). But, the traveler must know to call the airline and ask. DOT has not estimated the savings to travelers who would benefit from web specials they otherwise would not have known about, because it assumes these benefits would be offset by the loss in airlines’ revenues from selling a higher proportion of lower fare tickets. Accessibility might increase the overall amount of air travel by individuals with disabilities, but DOT thinks this effect would be small.

3. Reduced effort and frustration from use of existing air travel website: It might be possible to develop dollar values for this benefit, but DOT hasn’t attempted to do so.

4. Improved ability to make travel arrangements without relying on others’ assistance: DOT believes this is an important benefit that cannot be expressed in dollar values.

DOT expects that travelers with cognitive disabilities or conditions like epilepsy may also benefit from accessible redesign, but it has not tried to estimate the value of those benefits.

§3. Benefits for airlines

Currently, airlines must have staff to personally assist travelers who can’t use their websites because of disability, which is usually done over the phone. DOT estimates that accessibility would reduce these calls for assistance by 50%. A market research study estimates a cost of $5.50 per call. Over the projected number of travelers with disabilities, this means a savings to airlines of $11.77 million (undiscounted) over 10 years. (See RIA Table 21).

Also, the redesign process will give airlines (and, indirectly, large OTAs, see Websites: Which? What Content?) a better understanding of performance issues on their sites. And, because providing fully functional mobile versions and making primary sites accessible is the trend in computing, carriers’ and ticket agents’ corporate image may be improved. DOT has not tried to estimate a dollar value for these benefits.

Tier 2 estimates assume that carriers will comply at this stage by making the mobile version of their sites fully accessible. Retrofitting some pages of existing sites (the core-function pages covered by proposed Tier 2, see Websites: Implementation When?) is estimated to be comparatively more expensive than designing new compliant pages. DOT estimates that mobile versions have only 1/3 as many pages (20-300 pgs.) as carriers’ primary websites. Programming costs are estimated to be $150/hr. for very large and large sites, and $120/hr. for small and very small sites. Tier 2 compliance is estimated at $6,600 per site for very small carriers to $40,500 per site for very large carriers. Total cost for all 140 US and foreign carrier sites is $2.56 million (undiscounted) (See RIA Table 22).

Since Tier 3 affects medium and large travel agents/tour operators as well as carriers (see Websites: Which? What Content?), both groups are included in these cost estimates. To achieve full WCAG 2.0 Level AA compliance for primary sites, the estimated cost per site ranges from $31,200 for the smallest sites to $225,000 for the largest sites. Total Tier 3 costs are estimated at $36 million (undiscounted). (See RIA Table 23). This includes $17.4 million for the 188 affected carrier sites and $18.6 million for the 422 affected sites of medium to large travel agents/tour operators. (The number of carrier sites is greater than in Tier 2 because Tier 3 includes all carriers that market air transportation to the general public, even if their websites do not offer the core functions relating to ticket sales and check-in that Tier 2 affected. (See Website Implementation: When?)

Are there any carriers whose sites now comply with WCAG level AA? How much did those sites cost to develop?

Are DOT’s cost estimate components off? If so, by how much? Based on what data?

Is it possible to reasonably estimate time required to make accessible embedded content, such as PDFs and multimedia?

Are the initial costs of creating compliant websites different from creating noncompliant ones?

How much time will it take to make a traditional website compliant? A mobile version of the site?

What would be the cost and technical difficulty of making mobile versions accessible?

The annual costs of maintaining and upgrading primary sites to keep them compliant is estimated to be $2 million for carriers and $2.6 million for travel agents/tour operators. (See RIA Table 24). This assumes replacing or adding 20% of existing site pages each year. Per site cost for the largest sites is $23,400. (DOT noted in the Extension and Clarification that the per page maintenance costs had inadvertently been omitted from the formula used to compute costs for all the sizes other than the largest sites.)

Are the maintenance costs of an accessible site different than those of a nonaccessible site?

DOT recognizes other costs that are not easily expressed in dollar values: the opportunity costs of devoting resources to accessibility rather than other Web-based business strategies such as social networking; indirect costs of program management and training; and possible loss of creativity and design options if innovative Web content or functionality cannot be made accessible.

Are the costs for building an accessible website the same for airlines as they are for travel agencies? Travel agency websites include information from other types of travel (such as cruises) and it seems like these pages would have to be covered as well, so that would seem to make the costs higher for travel agencies. Or maybe I’m missing something.

Use these buttons to endorse, share, or reply to the preceding comment by tristatetraveler.

This is just another burdensome cost to airlines that will be passed along to travelers. We don’t need it. What regulation does the DOT propose eliminating to offset the cost of this proposal? Nothing, I’m sure.

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Kingslav, DOT has worked through the costs and benefits of this proposal and estimates that ultimately the benefits will outweigh the costs (you can see the breakdown in Table 25 of the Regulatory Impact Analysis). DOT has decided to act now because it considers marketing air transportation on web sites that are inaccessible to individuals with disabilities to be discriminatory and a violation of the Air Carrier Access Act. Do you think that DOT has considered everything it could?

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Hi, borge689. DOT wants help from you to check the accuracy of its estimates, provide additional information, and point out things it might have missed. The data is summarized on the lefthand side of this post. The full analysis can be accessed in the Regulatory Impact Analysis (RIA).

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Welcome to Regulation Room, borge689. It looks like you are addressing a potential benefit of kiosk accessibility, which can be found and discussed further Kiosks: Benefits and costs of accessibility post. Do you think there is a way for DOT to put a price on the benefits travelers will receive from not needing special assistance? DOT believes those benefits include increased independence, increased privacy, and an increased sense of inclusion.

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I agree good data is necessary for participation not just by disabled people in common activities but everyone and it is important that people have as much accessibility to all forms of interaction it also allows them to get around and give money not only to airlines but other sectors of the economy even if they arent going to make a big impact it still is just a step in the right direction

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Hi recon14193, and welcome to Regulation Room. It seems like you feel that the overall benefits, like better accessibility for people with disabilities and financial benefits to airlines, outweigh the costs. What do you think of King Slav’s comment below, that this cost is too much for airlines without enough benefit? Do you see any other benefits to airlines that might outweigh the costs?

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As a person with a mobility impairment, the more that I can manage my whole travel experience without a lot of interaction with staff, the more seamless my trip will be. At present, I try to do as much as possible online, but once at the airport I still need to negotiate red caps, security personnel, gate check-in personnel,luggage handlers and flight attendants,many of whom still do not have a clear idea of how to interact with people with disabilities. The kiosks will make little impact on this.

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Welcome to Regulation Room, aews175. It looks like you are addressing the proposed benefits to travelers with disabilities from kiosk accessibility, which can be discussed further at the Kiosks: Benefits and Costs of Accessibility post. It would be helpful if you told DOT specifically why the benefits they list have little impact and make specific suggestions on what could be done to make your travel experience easier.

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I strongly feel that more is needed in the way of better website access. Perhaps, as stated, airline personnel are supposed to waive the service fees for telephone reservations for disabled people, but my experience is that they often don’t. And when it comes to finding cheaper fares or less expensive alternative flight dates or times, they are no help at all. These are simple tasks for the non-disabled, but add greatly to both the cost and frustration of many disabled travelers.

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Thank you for sharing your personal experience with telephone reservations, alposner, and welcome to Regulation Room. Does anyone else have personal experiences they could also share about their issues with telephone reservations or air travel websites? DOT needs to know more about what people with disabilities are experiencing when they travel.

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I believe that websites should be available to people with all types of disabilities not just visual. People with cognitive disabilities as well as people with hearing disabilities and deaf/blindness also have issues related to air travel and website accessibility.

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Hi, jalexander. DOT thinks that accessible redesign may benefit people with nonvisual disabilities, but has not tried to quantify that value. What issues do you feel people with cognitive, hearing and deaf/blindness disabilities have with website accessibility? In what ways would an accessible website improve their air travel experience?

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